Transfer of shares of an Indian company under treaty with Mauritius
The AAR determined that capital gains realized on the transfer of shares are not taxable in India under provisions of the India-Mauritius income tax treaty. The AAR found that the control and management of the company was not wholly in India. The case is: Mahindra-BT Investment Company (Mauritius) Limited. Read KMPG September 2016 report [PDF 384 KB]